How to Document Nutrients to Preempt Regulation

May 24, 2016 12:00 PM
Corn Sky Field

Across Midwest crop country, top operators are waking up to a tough reality livestock producers have experienced for more than a decade: nutrient management regulations.

If your farm isn’t prepared to show when and where applications have occurred, experts say, the time to write a plan is now.

For example, in 2015 California flipped the switch to reduce volatile organic compounds—which produce greenhouse gases—by targeting certain pesticides, says Nishan Majarian, CEO of regulatory software provider Agrian.

“The state said, ‘We’re going to draw a line, and we’re not going to allow these pesticides to be applied after a certain date,’” Majarian recalls. “The next day, the entire state had to stop using those and start using something else. That’s very hard for a grower to manage a big shift in their production.”

In Deep Water

Calls for greater regulation of nutrients at the local, state and federal levels overwhelmingly flow from concerns of water quality. Of greatest concern for Midwest producers are excess nitrogen and phosphorus in the Gulf of Mexico, which have contributed to the growth of massive algal blooms that die, extract oxygen from ocean water and kill bottom-dwelling wildlife such as shrimp and fish. 

“Where are those excess nutrients coming from? The bulk are coming from upper Midwest states where it’s dark red on the map,” says Sean McMahon, referring to an illustration of U.S. Geological Survey data showing 41% of Gulf nitrogen and phosphorus stems from farm fertilizer (see maps below). As executive director of the Iowa Agricultural Water Alliance, McMahon is aware while farmers have made strides in using inputs responsibly, farming practices since 1950 have created challenges, too. 

“We’ve lost 10 million acres of pasture and small grains in Iowa,” McMahon says. “We no longer have some of the buffering capacity around our corn and soybean acres where we have plants in the spring and fall that are utilizing nitrate. That has really exacerbated our water quality challenges in Iowa.”

Nitrogen Contribution by State



Nutrients In Action

Producers can use the crawl-walk-run approach to document how they are addressing those water-quality concerns, Majarian explains. He recommends software such as Agrian because it aims to simplify the reporting process for producers by automatically updating forms and spreadsheets as soon as regulations change. 

“Twelve years ago, a lot of users did not want to use Agrian or any system because their thought was, ‘If I don’t have a record, I can’t get in trouble if there’s a problem,’” Majarian says. “Obviously something has changed because we just passed 630 million treated acres.”

In crawl mode, producers should use low- or no-cost tools from their ag retailer, who can visit fields and create digital files for future tracking of nutrient applications, he says. In walk mode, producers use their chosen software tool to write down and document applications. 

Phosphorus Contribution by State




Expert Insights Critical

Finally, in run mode, producers can combine their own knowledge of field applications with results from laboratory soil tests, giving them a field-by-field view of nutrient use. Also use retailers and agronomists as trusted experts on new nutrient laws and regulations, Majarian suggests.

“They understand nutrient needs and can assist the grower in documenting the good work they’ve both done on that grower’s field,” he says. 

Few are more aware of the need for nutrient management plans than livestock producers. In Illinois, they have faced multiple regulations since 1997, when the Illinois Livestock Management Facilities Act took effect, says Ted Funk, Extension specialist in agricultural engineering at the University of Illinois. 

He believes most crop producers don’t fully appreciate the intensive record-keeping already in place for many cattle and hog farmers.

“I don’t think they’re prepared for the level of scrutiny that the Chesapeake Bay and the Lake Erie basin have been exposed to,” Funk says. In Illinois, large livestock operations face up to four layers of nutrient management reporting:

1. Basic manure management records. Farmers must document manure production, conduct manure testing and calculate state-approved rates of application. 

2. Intermediate manure records. Larger producers must document manure produced annually, locations at which manure has been applied at agronomic rates and more.

3. Comprehensive Nutrient Management Plan. Although not a regulatory requirement, this plan is mandatory for operations seeking federal Environmental Quality Incentives Program (EQIP) funding. 

4. National Pollutant Discharge Elimination System. Rarer still, this reporting is administered through EPA’s Illinois offices and is required of operations that discharge to waters of the U.S.

Funk says nutrient management plans such as these are valuable: they allow farmers to make better economic use of inputs and emphasize high environmental standards. 


To find resources and links to help make your voice heard on key issues facing farmers, visit

Farmer: More Record-Keeping Is Ahead

There’s no doubt in producer Rod Wilson’s mind that regulations will eventually require him and other farmers to keep even better records of nutrient applications. For now, though, Wilson—who farms 2,700 acres of corn and soybeans in east-central Illinois—is careful to keep written and electronic records to document nutrient usage on his fields year to year.

      Rod Wilson uses field zones to      manage inputs. 

“It’s not going to be hard for us to transition into whatever requirements there are as regulations are put into place,” Wilson says. He notes he has always been sensitive to applying the “optimum it takes to produce an economically viable crop” in light of his operation’s location in the Salt Creek Watershed near Clinton Lake, a 4,900-acre recreational reservoir. 

“The environment I’ve worked in has dealt with fragile soil types,” Wilson explains. “We’ve done a lot of conservation work as far as terraces and waterways. For me, it’s always been second nature to be cognizant of how we apply fertilizers, and soil movement, and try to reduce losses.”

The operation applies dry fertilizers and lime in the fall, and liquids in the spring and growing season based on soil-test recommendations. 

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